HONG KONG SAR, CHINA Trends and Developments Contributed by: Pang Lee, Joyce Wang, Mark Liang and Francis Li, Cooley
and intended user base – become as critical as the underlying technology design. The regime was launched alongside transitional provi- sions aimed at pre-existing stablecoin issuers. These include time-bound windows governing whether an issuer may continue operations while its licence appli- cation is under review, and when a mandatory wind- down process is triggered in the absence of a valid application. A second, often underappreciated, compliance lever is marketing and advertising. The government made clear that even during any non-contravention period, only advertisements relating to licensed FRS issu- ance are permitted, as part of broader anti-scam and anti-misleading safeguards. The practical implication is that go-to-market strategies for stablecoins must treat licensing status and marketing compliance as first-order constraints. This extends beyond traditional advertising to include influencer campaigns, referral programmes, token listing announcements and even whitepaper distribution. On 10 April 2026, the HKMA announced the first sta- blecoin issuer licences, granted to (i) Anchorpoint Financial, a joint venture involving Standard Chartered Bank (Hong Kong), Hong Kong Telecom (HKT) and Animoca Brands; and (ii) HSBC. This milestone confirms that the regime is fully oper- ational and conveys a clean strategic message that Hong Kong is positioning stablecoins as part of a regulated financial infrastructure aligned with real- economy and institutional use cases, but not as light- ly supervised retail speculation instruments. Just as importantly, it signals the profile of licensees the HKMA is prepared to approve at the initial stage, including participation from major banking institutions. It is not surprising that the first batch of licensees already pos- sess deep KYC and AML knowledge, which is con- sistent with HKMA’s clear expectation that stablecoin issuers must be able to implement AML/CFT systems to comply with relevant legal and regulatory obliga- tions and manage money laundering/terrorist financ- ing risks effectively. The HKMA also disclosed that it received 36 applications in the first batch (by 30 September 2025 deadline) and indicated that, based
on licensees’ business plans, regulated stablecoins are expected to launch in mid-to-late 2026. VATP Licensing: A Concentrated Base With an Expanding Scope of Permitted Activities Hong Kong continues to anchor its regime in the licensing of centralised exchanges operating in, or actively marketing into, the local market. The SFC maintains and publishes the list of licensed VATPs , which, based on current disclosures, includes plat- forms such as OSL and HashKey Exchange. Hong Kong’s approach to retail participation in vir- tual asset trading remains deliberately calibrated. Under the VATP Guidelines, retail trading is limited to “eligible large-cap virtual assets”, which must, at a minimum, be included in at least two acceptable indices from separate index providers. In practice, this makes token listing as much a compliance exercise as a commercial decision. Listing committees, index eligibility monitoring, disclosure standards and post- listing surveillance become continuous operational requirements. These obligations are particularly rel- evant in environments of high volatility, token forks or changes in index construction methodologies. In February 2025, the SFC introduced its “ASPIRe roadmap” covering Access, Safeguards, Products, Infrastructure and Relationships (ASPIRe). More than a policy statement, ASPIRe served as the organising framework for subsequent regulatory guidance, circu- lars and permissions throughout 2025 and into 2026. Hong Kong is pursuing a regulated expansion path- way, rather than operating a static rulebook. Where a product or activity is explicitly identified under one of the ASPIRe pillars (eg, liquidity access under Pil- lar A or product diversification under Pillar P), there is a greater likelihood that the SFC will establish a controlled route to market, rather than forcing such activity into offshore or unregulated channels. Product and Market Structure Expansion Regulated staking: from prohibition to conditional permission A major development in 2025 was Hong Kong’s shift away from a blanket prohibition on generating returns from client virtual assets towards a regulated pathway for staking. On 7 April 2025, the SFC issued guidance
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